Plaintiffs, by undersigned counsel, respectfully submit this Motion for Leave to Supplement Pending Motion Regarding Deposition of Betsy Pond and Supplement Thereto. As grounds therefor, Plaintiffs state as follows:

MEMORANDUM OF LAW

Plaintiffs’ motion and reply briefs set forth their concerns about the deposition testimony of Betsy Pond, and propose certain remedial measures designed to maximize the chances for candid, truthful, and relevant testimony from her. As the Court knows, Linda Tripp recently testified that it was Betsy Pond who told her that she was inputting data from FBI files onto a computer in the White House Counsel’s Office. Ms. Tripp also testified later that she overheard a conversation between William Kennedy, Senior Associate in the White House Counsel’s Office and former law partner of Hillary Clinton’s at the Rose Law Firm, and Marsha Scott, former close confidante of the President (according to Linda Tripp) and, at the time, Director of Presidential Communications, where the two were discussing Hillary Clinton’s directions to share information in the files with the Democratic National Committee ("DNC"). When Ms. Tripp brought this to the attention of Bruce Lindsey – who she trusted at the time he responded by saying "talk like that will get you destroyed."

A review in the last few days of the book The Secret Life of Bill Clinton has revealed that, in addition to having worked in the White House Counsel’s Office for Bernard Nussbaum and William Kennedy, and having told Linda Tripp that she would never testify truthfully about what she had observed, "Betsy Pond [is] a Clinton loyalist who had worked as a secretary with Hillary Rodham on the Watergate impeachment inquiry."

Given all of this information, it is logical to assume that if, as Ms. Tripp testified, FBI files were being loaded onto White House computers to be shared with the DNC at the direction of Hillary Clinton, Mrs. Clinton would have chosen a long-time and very close loyalist to do it. This also likely explains Ms. Pond’ reticence to tell the truth, as admitted to Linda Tripp. It also likely explains why Ms. Pond is now a high-level assistant to Attorney General Janet Reno at the very same Justice Department which, through the FBI, is not only counsel in this case, but also a defendant.

Also interesting and telling is that Ms. Pond is being represented by Sidley & Austin. Sidley & Austin not only recently hired an attorney from the White House Counsel’s Office, but also represents Stephen Waudby, an assistant who worked in the White House Counsel’s Office and who Betsy Pond sent to Sidley & Austin for legal representation just after she was implicated in Filegate by Linda Tripp. At his deposition, Mr. Waudby testified that Ms. Pond had recently given him a gift and sold him her car for $1,500 below market value. Also, when asked who was paying for his legal representation, Mr. Waudby initially would not respond, until after he took a break and conferred with his counsel.

In sum, the circumstances behind and related to the testimony of Betsy Pond are significant to Plaintiffs’ case and Plaintiffs respectfully require the Court’s guidance on how to proceed under these unusual circumstances.

Respectfully submitted,

JUDICIAL WATCH, INC.

_________________________

Larry Klayman, Esq.

DC Bar No. 334581

_________________________

Deborah E. Berliner, Esq.

DC Bar No. 422238

Suite 725

501 School Street, S.W.

Washington, DC 20024

(202) 646-5172

Counsel for Plaintiffs

LOCAL RULE 108(m) CERTIFICATE OF COUNSEL

On April 2, 1999, I contacted counsel for Defendants and non-party witness Betsy Pond, by telephone, to inquire whether their clients would consent to the relief requested herein. Counsel for the Government Defendants, Elizabeth J. Shapiro, Esq., and counsel for Betsy Pond, Jeffrey T. Green, Esq., advised me that they would oppose the instant motion. Counsel for Defendant Hillary Rodham Clinton, Marcie R. Ziegler, Esq., needed to inquire and advised she would call back. Paul B. Gaffney, Esq., returned her call and advised me that they would oppose the requested relief.

Upon consideration of Plaintiffs’ Motion For Leave to Supplement Pending Motion Regarding Deposition of Betsy Pond And Supplement Thereto, any opposition thereto, and the entire record herein, it is hereby

ORDERED that:

1. Plaintiffs’ motion is granted; and

2.Plaintiffs’ supplement is hereby deemed filed.

SO ORDERED.

DATE:_______________ ______________________________

The Honorable Royce C. Lamberth United States District Judge

Copies to:

Attorneys for Plaintiffs:

Larry Klayman, Esq.

JUDICIAL WATCH, INC.

501 School Street, S.W.

Suite 725

Washington, D.C. 20024

Attorneys for Defendants Federal Bureau of Investigation and Executive

Office of the President:

James J. Gilligan, Esq.

Elizabeth J. Shapiro, Esq.

Julia Fayngold Covey, Esq.

U.S. DEPARTMENT OF JUSTICE

P.O. Box 883

Washington, DC 20044

Attorneys for Defendant Hillary Rodham Clinton:

David E. Kendall, Esq.

Paul B. Gaffney, Esq.

Marcie R. Ziegler, Esq.

WILLIAMS & CONNOLLY

725 12th Street, N.W.

Washington, DC 20005

Attorneys for Non-Party Witness Betsy Pond:

Myles E. Fling, Esq.

Jeffrey T. Green, Esq.

SIDLEY & AUSTIN

1722 Eye Street, N.W.

Washington, DC 20006

CERTIFICATE OF SERVICE

I hereby certify that on April 5, 1999 a true and correct copy of the foregoing Plaintiffs’ Motion For Leave to Supplement Pending Motion Regarding Deposition of Betsy Pond And Supplement Thereto was served via first-class U.S. mail, postage prepaid, on the following: